Transcription of Addressing hybrid mismatch arrangements - …
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Addressing hybrid mismatch arrangements - …
Addressing hybrid mismatch arrangements A Government discussion document Hon Bill English Minister of Finance Hon Michael Woodhouse Minister of Revenue First published in September 2016 by Policy and Strategy, Inland Revenue, PO Box 2198, Wellington 6140. Addressing hybrid mismatch arrangements A Government discussion document. ISBN 978-0-478-42436-2 CONTENTS INTRODUCTION 1 PART I Policy and principles 3 CHAPTER 1 Background 5 Historic focus on the problem of double taxation 5 The problem of double non-taxation 5 G20/OECD Action Plan 6 hybrid mismatch arrangements 6 OECD recommendations 7 Implementation of OECD recommendations 7 CHAPTER 2 hybrid mismatch arrangements 8 hybrid instruments 9 hybrid entities 12 Indirect outcomes 15 CHAPTER 3 Policy issues 16 Global impact of hybrid mismatch arrangements 16 Uptake in other countries 18 Impact of hybrid mismatch arrangements on new zealand 18 CHAPTER 4 OECD recommendations 22 hybrid mismatch rules OE
If New Zealand were to adopt the OECD anti-hybrids recommendations, the rules would apply to foreign companies doing business in New Zealand as well as New Zealand-owned companies doing business offshore.
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